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EFTA01390028

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GLDUS138 Ian Slome iCapital Advisors, LLC Form ADV Part 2A investment. Certain management persons of iCapital (or its affiliates) are also involved with soliciting investment advisers to participate in iCapital offered funds and in performing diligence on such investment advisers with which to launch access vehicles. Such relationship may create potential conflicts of interest. iCapital addresses these conflicts by providing in its Code of Ethics that all supervised persons have a duty to act in the best interests of each investor and by providing training to supervised persons with respect to conflicts of interest and how such conflicts are resolved under the iCapital's policies and procedures. Furthermore. compensation for management persons is not based on any transaction-based compensation received by iCapital Securities (or its affiliates). Fees Paid by Brokerage Limited Partners. Limited partners in one or more of the Funds may elect to be treated as "brokerage limited partners" and in connection therewith, pay a larger management fee than limited partners that are not "brokerage limited partners" for reporting, administrative and other services provided by such brokerage limited partner's registered investment adviser or adviser representative. The amount of any such additional management fee will generally be allocated to third parties or affiliates that provide investor-related services, including such brokerage limited partner's adviser representative. The existence of such fee may incentivize an investor's registered investment adviser or adviser representative to recommend a Fund over other investments from which such registered investment adviser or adviser representative would not receive such fee. Estimates. The governing documents of each Fund provide that values of the Fund's assets shall generally be calculated by the Fund's administrator based on estimates provided by the applicable Underlying Fund Manager or Sub-Adviser.

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